evaluation of the facts in light of the relevant standards of care. Conducting due diligence is not a mechanical process and it requires exercise of informed and seasoned judgement by the investigator. “Because the hard and soft laws governing corporate human rights responsibilities are evolving, respecting the letter and spirit of international human rights is the appropriate standard of care to apply in human rights due diligence.”33 The duty to respect and protect human rights obligates business enterprises to exercise due diligence processes including (1) assessing actual and potential impacts of business activities on human rights; (2) acting on the findings of the assessment, including by integrating appropriate measures to address impacts into company policies and practices; and (3) communicating to the outside world about the due diligence process and results.34 These processes are not unlike the “reasonable steps” that business enterprises are commonly expected to take to comply with various national legal regimes. As a result, many business enterprises, particularly those with longevity and global reach already operationalize due diligence processes as a matter of corporate management.35 Additionally, the scope of due diligence includes addressing adverse human rights impacts that the business enterprise may cause or contribute to through its own activities, or which may be directly linked to its operations, products, or services by its business relationships. Further, this process should be on-going and involve meaningful consultation with potentially affected groups and other relevant stakeholders.36 The Guiding Principles are intended “to prevent business enterprises from escaping responsibility through the outsourcing of potentially harmful activities to others through their business relationships.”37 As noted above, this includes being held accountable for climate impacts.38 As early as 1968, the American Petroleum Institute (API) funded research in atmospheric science to study the causes and impacts of rising carbon dioxide concentrations in the atmosphere. The Robinson Report, released in 1968 and then supplemented in 1969, cautioned that “rising levels of CO2 would likely result in rising global temperatures and warned that if temperatures increased significantly, the result could be melting ice caps, rising sea levels, warming oceans and serious environmental damage on a global scale.”39 It further acknowledged that “melting ice caps, if they occurred, would obviously result in inundation of coastal areas.”40 The report also acknowledged that fossil fuel burning provided the best explanation for rising CO2.41 By the late 1970s and 1980s, reports exchanged between the oil industry and the Department of Energy demonstrate that the oil industry was on notice about climate change, what was causing it, and 33 See Mark Taylor, Luc Zandvliet & Mitra Forouhar, Due Diligence for Human Rights: A Risk-Based Approach 3 (Oct. 2009). 34 See supra note 27, at 18 (citing the Human Rights Due Diligence Report (2012)). 35 The process for business enterprises to conduct Human Rights due diligence under the Guiding Principles is not unlike well-established actions under risk assessment and management methodologies applied in corporate finance and infrastructure development among other industries and sectors. 36 See Petition GP at pdf 35; United Nations Commission on Sustainable Development, Rio Declaration, Fifth Session, April 25, 1997 at Principle 17. 37 See Mark B. Taylor (ICAR), Human Rights Due Diligence: The Role of the States 13 (2013 Update), available at http://icar.ngo/wp-content/uploads/2013/11/ICAR-Human-Rights-Due-Diligence-2013-Update-FINAL1.pdf. 38 See OHCHR, Discussion Paper: Understanding Human Rights and Climate Change, supra note 29. 39 See Synthesis Report supra note 4. 40 E. Robinson & R.C. Robbins, Supplemental Report (1969) (on file with CIEL). 41 Id. 10